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Supreme Court of India 2026-01-06 allowed

Commissioner of Customs (Import) vs Welkin Foods

Bench: 2 — J.B. Pardiwala, R. Mahadevan

In Brief

An importer claimed aluminium shelving for mushroom cultivation should be classified as agricultural machinery parts (nil duty). Customs classified them as aluminium structures (10% duty). The Tribunal sided with the importer based on end-use. The Supreme Court reversed, holding that goods must be classified by their inherent nature at import, not intended use, unless the tariff heading explicitly permits considering use. The Court clarified that classification follows statutory tariff terms and GRI rules sequentially; end-use arguments cannot override these unless specifically allowed by the tariff schedule itself. Aluminium shelves are structures, not machine parts. Appeal allowed, duty classification restored.

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Customs Classification Tariff Interpretation Agricultural Machinery General Rules of Interpretation End-Use Doctrine Common Parlance Test Intended Use vs Actual Use Harmonised System Nomenclature Eo-Nomine Headings HSN Explanatory Notes

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